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SPIN Changes, Split FRNs, and 486s
Message Posted June 22, 2006
Yesterday I sent a message to the listserve showing which entities had 486s that were either due or overdue for Funding Year 2005. In many of the cases, the applicant apparently inadvertently missed listing a single FRN on their original Form 486. However I'm noticing a trend for several other missing 486s and it's due to a Split FRN issue. Therefore I'm writing with a primer on Split FRNs, how SPIN changes are often Split FRNs, and what additional steps are needed when a Split FRN occurs (see especially # 3).
When applicants change service providers after funding has been approved, they must request a SPIN change with the SLD (instructions for doing so are at: http://www.universalservice.org/sl/about/changes-corrections/spin-change-guidance.aspx). There are three types of SPIN changes:
1) When You Need To Correct a SPIN Typo:
If the applicant inadvertently listed the wrong service provider on the Form 471, typically due to a typo, the applicant should request a Corrective SPIN change. It's best to try to get these corrected before the funding commitment is made through the PIA review process, but it can be done after funding is committed using the Corrective SPIN change process.
2) When the Provider Has Changed, AND the New Provider Has Provided All Services Since the Start of the Funding Year:
If the service provider listed on the original Form 471 changes, and the new provider has been providing services for the entire funding year, the applicant should notify the SLD of an Operational SPIN change. The following certification must be made when requesting an Operational SPIN change "I certify that (1) all SPIN changes requested in this letter are allowed under all applicable state and local procurement rules, (2) the SPIN changes are allowable under the terms of the contract, if any, between the applicant and its original service provider, and (3) the applicant has notified its original service provider of its intent to change service providers." In this case, the SLD will change the SPIN in their databases, keep the original FRN number, and notify the applicant that the SPIN change has been approved. The applicant does NOT have to refile the Form 486 for the new provider.
3) When the Provider Has Changed Mid-Funding Year OR the Service is Split Between Two Providers:
If the service provider listed on the original 471 changes mid-funding year and the service will be provided by two different vendors within the same funding year, the applicant must request a SPLIT FRN. There is actually no guidance on the SLD website describing a SPLIT FRN, but the impact of filing an Operational SPIN change and stating that two vendors are providing services under the same FRN in the same funding year, will be that the SLD will consider it a SPLIT FRN (whether the applicant calls it that in their correspondence or not). In this situation, the SPIN change guidance requires the applicant to list the # of months that each service provider has or will be providing services and the amount of the original funding commitment that should be allocated to each vendor.
Important: After the SPLIT FRN is approved, the SLD create a new FRN for the amount of funding that has allocated to the new service provider. A revised Funding Commitment Decision Letter also will be mailed to the applicant showing the original FRN, now with reduced funding, and the new FRN showing its share of the original funding. Because a new FRN has been created, the applicant then must file a new Form 486 for that FRN within 120 days of the date on the revised Funding Commitment Decision Letter. The following entities listed on yesterday's Form 486 Due message are affected by the SPLIT FRN issue and therefore may not have been aware of the new Form 486 filing requirement:
FRN Applicant Name
1360040 ARMSTRONG SCHOOL DISTRICT
1363715 B F JONES MEMORIAL LIBRARY
1450977 FRIENDSHIP HOUSE SCHOOL
1493460 LAKELAND SCHOOL DISTRICT
1493461 LAKELAND SCHOOL DISTRICT
1321751 LYCOMING COUNTY CAREER CONSORTIUM
1492584 LYCOMING COUNTY CAREER CONSORTIUM
1392793 NESHANNOCK TWP SCHOOL DISTRICT
1360010 PENNSYLVANIA SCHOOL FOR DEAF
1360009 PENNSYLVANIA SCHOOL FOR DEAF
1373506 PIKE COUNTY PUBLIC LIBRARY
1493320 SERRA CATHOLIC HIGH SCHOOL
1362707 SOUTHERN FULTON SCHOOL DIST
1493502 ST PHILIP NERI SCHOOL
I hope this helps explain the Split FRN process and requirements. If you have any additional questions, please don't hesitate to contact me.
Julie Tritt Schell
jtschell@comcast.net
www.e-ratepa.org
(717) 730.7133 (voice)
(717) 730.9060 (fax)
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